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Alabama Department of Human Resources (#04-98-7404)

CERTIFIED MAIL-RETURN RECEIPT REQUESTED

May 17, 2000

Mr. Tony Petelos, Commissioner
Alabama Department of Human Resources
S. Golden Persons Building
50 Ripley Street
Montgomery, Alabama 36130-4000

Re: Compliance Review Number 04-98-7404

Dear Mr. Petelos:

The Office for Civil Rights (OCR) of the United States Department of Health and Human Services (DHHS) has completed its review of the Alabama Department of Human Resources (DHR), Division of Family Services. The subject review was conducted under Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000 et. seq.), and implementing regulations as found at 45 C.F.R. Part 80, and the Multi-ethic Placement Act of 1996 (MEPA), 42 U.S.C. Sections 5115a, and Section 1808 ? of the Small Business Job Protection Act of 1996 (Removal of Barriers to Inter-ethnic Adoption), 42 U.S.C. Section 620 et.seq.. The foregoing statutes prohibit the use of race, color, or national origin as a basis for any delay or denial in foster or adoptive placements by receipts of Federal financial assistance.

BACKGROUND

OCR has the discretion to conduct periodic reviews to determine whether recipients of Federal financial assistance operate their programs in compliance with Title VI 45 C.F.R. Section 80.7. Pursuant to this authority, our office initiated a review of DHR to determine if its foster care policies and practices are implemented in a non-discriminatory manner. The review focused primarily on the State office and three local agencies situated in Montgomery, Mobile, and Jefferson counties. In conducting this review, our office consulted with the Administration for Children and Families (ACF), also of the DHHS, and collected and analyzed data obtained from that agency as well as from DHR.

Member's of DHR's civil rights staff participated in the on-site investigation portion of our review which was conducted during the week of June 1, 1998. They teamed with OCR's representatives in conducting interviews and reviewing pertinent records and documents.

They also assisted in contacting sources in the community who had knowledge and familiarity with the implementation of DHR's foster care program. OCR acknowledges and appreciates the valuable and cooperative assistance provided by DHR's entire staff, particularly members of the civil rights unity, during the course of the subject investigation. This letter is to notify you of the results of our investigation

JURISDICTION AND STATUTORY AUTHORITY

OCR is the agency within DHHS responsible for enforcing the nondiscrimination requirement of Title VI of the Civil Rights Act of 1964 (Title VI) and Section 1808 ? of the Small Business Job Protection Act of 1996. Pursuant to 45 C.F.R. Section 80.7(2) of the Title VI regulation, OCR is authorized to conduct periodic compliance reviews of the practices of recipients of Federal financial assistance from DHHS to determine whether their programs and activities are being conducted without discrimination on the basis of race, color, or national origin.

ISSUE

Whether DHR selects foster parents and places children with them without regard to race, color, or national origin as required under Title VI and MEPA, and implementing regulations, 45 C.F.R. Sections 80.3(a), (b), (1), (I),(ii), (iii),(iv),(v),(vi), and (b)(2).

DISCUSSION/ANALYSIS

Our review determined that while DHR has oversight responsibility for the foster care programs operated locally by each of the 67 counties in the state, it does not employ nor supervise the county employees working in this area. Each local program is under the administrative control of a "County Director of Human Resources" who in turn is responsible to a "County Board of Human Resources". In carrying out its oversight duties, DHR establishes and disseminates foster care policies, procedures, regulations, and directives. The local boards are responsible for appointing staff, formulating general policies, rules, and guidelines which are consistent with those established by DHR.

The investigation established that DHR disseminates policies and procedures applicable to several aspects of the foster care program including recruitment, the application process, training, and placements. Our examination of these policies discloses that they not include considerations regarding the race, color, or national origin of the affected children to prospective foster parents. There were no processing or assessment standards in the criteria reviewed during our investigation requiring program participants to be subjected to different standards, or in any way treated in a disparate manner, on a prohibited basis. Accordingly, we find that the foster care policies promulgated by DHR comply with Title VI/MEPA.

While the contents of the subject policies appear to be non-discriminatory, OCR's investigation did establish that program materials are not effectively disseminated in al cases. For example, the record reflects that on November 28, 1995, and on November 7, 1997, DHR issued, respectively, memoranda entitled "Removal of Barriers to Inter-ethnic Adoption", and "Recruitment of Foster Care and Adoptive Parents". Attached to this latter memorandum was a guideline entitled "Necessary Components of Effective Foster Care and Adoption Recruitment". However, several of the case workers and others responsible for implementing the foster care program at the county level who participated in OCR's investigation stated specifically that they were unaware of the foregoing documents. Because these workers did not know that the subject memoranda existed, they were unfamiliar with the guidance and directions contained therein. They candidly admitted that no steps had been taken to assess the extent to which their placement practices were consistent with the guidance reflected in the directives cited earlier. In short, our review established that DHR lacks adequate measures to ensure that pertinent program materials are in fact disseminated to necessary staff at the local level. DHR needs to undertake appropriate steps to overcome this deficiency in order to make sure that its ability to conduct the foster care program in compliance with Title VI/MEPA is not impaired. One way DHR may address compliance concerns arising from this deficiency is to enter into a voluntary compliance agreement which contains appropriate measures to address the same. Necessary corrective measures would have to include provisions such as those provided in the enclosed proposed agreement which, among things, require DHR to take steps to ensure that local case workers: (I) do in fact receive materials promulgated by the state office; and (ii) actually follow any guidance provided therein in carrying out their responsibilities in the foster care program. As mentioned above, the local areas involved in the subject review included Montgomery, Mobile, and Jefferson counties. Following is a summary of our findings pertaining to each of these locales.

Montgomery County Our investigation established that the written policies and procedures in effect in Montgomery County mirror those promulgated by the state agency. The written procedures and policies applicable to the processing of applications, recruitment, training, and placement that were examined by OCR do not explicitly require considerations regarding the race, color, or national origin of program participants. Information reviewed by our office discloses that recruitment efforts undertaken in the County are directed at the entire service area and do not target particular groups or communities. The written criteria applicable to placement determinations do not require that such decisions be handled differently due to race, or in any way appear to involve considerations prohibited under Title VI/MEPA. In addition to its written provisions, the review also disclosed that several aspects of the foster care program in Montgomery County are being conducted in a non-discriminatory manner. To illustrate, according to 1990 census data there were 209,085 residents in this area at that time of which 119,420, or 57.0%, were White, while 90,883, or 43% were Black. The records show that in 1997, there were a total of 185 children in the County/s foster care system, of which 37, or 20% were White, and 148, or 80% were Black. Records reflect that during 1997, 42 persons applied to become foster parents and of this number 8, or 19% were White, and 34, or 81% were Black. Of this total, the County approved 13 applications, 4, or 31% of whom were White, and 9, or 69%, were Black. These figures indicate that minorities sought to serve as foster care parents, and were approved by the County for this role, at rates that were roughly commensurate with their presence in the area. The data obtained and reviewed by OCR tend to confirm that minorities are recruited and approved as foster parents in a non-discriminatory manner. During the course of the subject review we examined information addressing whether foster placements were being made in Montgomery County irrespective of the rave of the prospective foster parent or child involved. In this regard, the records show that in 1997 there were a total of 9 trans-racial placements in the County, 5 of which involved White children placed with Black Parents, while 4 involved Black children placed with White parents. (We should note that 2 of the 4 trans-racially placed Black children were a sibling group together). However, our review also established that two of the subject placements were considered long-term as the others were for temporary, and/or, emergency purposes. Specifically, records reveal that one of the long-term trans-racial placements were all temporary. Interview comments made by case workers responsible for handling placements provide some insight as to why the foregoing figures reflect a near total lack of trans-racial pairings. Answering a question posed regarding the factors considered while making placement determinations, one case worker responded that initially "...we try to place children with their own race; however, we have children placed in homes of the opposite race. There are bi-racial homes where children are placed in both Black and White homes, but when a child is placed in a home of a different race, the County tries to make sure that the child is going to be exposed to his/her own culture as well. For instance, is a Black child is placed in a White home, and the family goes to an all White church and they live in all White neighborhood, that would be an inappropriate placement for that child. The County will try to place the child in an interracial neighborhood. Although this worker explicitly admitted to having no knowledge of any written policies or procedures mandating that placements be carried out in this manner, the worker was unable to articulate how the County's "practice" requiring same race placements was originated.. Even so, this worker added, however, that the practice was followed because "That's just the way we feel". The case worker went on to explain that this attitude is based on the realization that" It's a lot for children to be removed from their family members and going into a home with total strangers. So to place a Black child in a White home, that's even more detrimental to that child when he is accustomed to living with one race. So it's my personal opinion, I guess to place that child with their culture".

As reflected above at the end of her response the worker used the word "culture"; however, it is strongly evident that this term as used here was intended as a substitute for race given the substance of the overall response and the fact that the particular question being addresses was directed at the actual practices implemented by the worker in regards to trans-racial placements. The foregoing contrasted somewhat with the opinion of a few other workers who, while expressing similar views that it was important to place children "within their own culture", nonetheless tended to appear to emphasize factors other than race. For example, during one interview a worker indicated that the "cultural heritage" as reflected by the alleged unique religious and dietary (vegetarian) needs of a child from ?East India" should be considered in arriving at an appropriate placement determination. In this particular case, the overall tenor of the workers remarks did not create the impression that race or ethnicity was included among the factors assessed to determine a suitable placement capable of addressing the child's cultural needs.

But in many other instances, the case workers who participated in OCR's investigation clearly noted that it was their practice to seek same race placements, at least initially, primarily because of concerns pertaining to race and/or culture. To illustrate, in addressing the topic of trans- racial placements, one worker observed that when children came into the County's care, "..it would be better and easier for the children to go into an environment to which they were accustomed rather than a strange one". The explanation offered by one worker in support of this belief centered on the fact that when families express feelings about taking children of a different race into their homes, they allegedly regularly mention the potentially negative attitudes and feelings of not only the neighborhood where they love, but also of their own immediate and Montgomery County contacted by OCR admitted that it was their practice to place children with foster parents of the same race.

The foregoing admissions reflect that the County has a practice of routinely placing a priority on first locating same race placements before even considering suitable parents of races different than the children involved. By using race as a disqualifier at the outset of the placement process, the County in effect arbitrarily reduces the pool of the prospective parents who might be otherwise capable of meeting the specific needs of a given child. This practice therefore may inevitably and unnecessarily in come cases increase the time expended to effect placements.

p>In addition to delays, the subject practice also may cause placements to be constructively denied in those cases where adherence to the County's prioritization policy preludes consideration of any and all otherwise suitable prospective parents who readily available but racially different from the children being placed. A violation of Title VI/MEPA would be established if it were demonstrated that placement delays and denials were actually caused by such a race-based prioritization practice. This practice also constitutes a violation of the foregoing provisions because facially it requires that program participants receive preferential consideration solely on the basis of race-an approach which, as discussed above, inevitable involves placement delays and even denials in some cases.

 

Putting children in apparently suitable transracial settings but only on temporary basis and only until a same-race placement is secured placement is secured illustrates another invidious effect of the County's acknowledged, race-based, prioritization placement practice. According to the testimony of case workers participating in OCR's investigation, transracial placements are viewed only as temporary situations solely because the children and foster parents are of different races. Arbitrarily viewing transracial placements as basically short-term options would appear to greatly limit the County's ability to achieve the important goal of expeditiously finding long- term placements suitable for the specific needs and circumstances of all children entrusted to its care. In addition to this apparent program deficiency, however, under such a practice the County effectively assesses prospective parents as candidates for only a certain type of placement, i.e., temporary/emergency, solely because of race.

Determining whether to assess long-term or short-term placements as viable options solely on this basis typifies the implementation of program criteria in ways prohibited under Title VI/MEPA. Under these provisions, the County must apply all program criteria without regard to the race of the program participants. However, the acknowledged race-based placement practices being followed by staff in Montgomery County on their face interject consideration of race in the placement practices in ways that are likely to cause the type of placement denials or delays prohibited under Title VI/MEPA. To correct this violation and to ensure that DHR's placement practices comply with Title VI/MEPA, the agency must: (I) undertake appropriate steps to eliminate the subject practice; and (ii) , institute measures to ensure effective monitoring to guard against t any re-occurrence. Necessary steps to address this problem we feel are included in the enclosed proposed voluntary settlement agreement.

Mobile

Similar to the situation that was found in Montgomery, the information obtained during the course of our review and examined by OCR disclosed that the written foster care policies and procedures in effect in Mobile County are the same as those developed by the state agency. The written procedures and policies pertaining to the processing of applications, recruitment, training, and placement do not require consideration regarding the race, color, or national origin of program participants. Recruitment efforts undertaken in Mobile County involve the entire community and are not limited to certain population segments of the area. The stated criteria applicable to placement determinations do not require that such decisions be handled differently due to race, or in any way appear to involve considerations prohibited under Title VI/MEPA.

Census data reviewed by OCR show that in 1990 there were a total of 378,643 persons residing in Mobile County. Of this total, 254, 853, or 67% were White, while 117,872, or 31%, were Black, and 8502, or 2%, comprised other minorities. During the time of our on-site visit, documentation provided to OCR indicates that there were 626 children in foster care and this total 221, or 35%, were White, 400 or 64%, were Black, and 5 or 1%, were classified as other minorities. At that time records disclosed that there were 154 active foster parents in Mobile County, and approximately 93 or 60%, were Black, while 61 or 40%, were White. Information we obtained reflects that during the year preceding our review, there had been five transracial placements: 3 Black parents with White children; 1 White parents with Black children; and 1 White parent with a Native-American child.

Our review established that "Foster Care Resource Unit", which comprises a staff of six, is responsible for training, supervising, recruiting and approving foster homes. Information obtained by our office reveals that individuals are approve as foster parents in a non- discriminatory manner. For example, records show that during the year preceding our review Mobile County received 61 foster parents applications of which 34, or 56%, were from Blacks and 27, or 44%, were submitted by Whites. The County approved 37 of the applications it received during this time. Of those accepted, 22, or 59%, were Black, while 15, or 41%, were White. We found no evidence that persons seeking to become foster parents were subjected to discrimination during either the application or approval processes. However, our review uncovered problems in other aspects of Mobile's County's foster care program. For example, the three persons holding Social Worker II positions who work exclusively with foster care parents participated in OCR's review. Although, as indicated above, the County has written policies and procedures applicable to foster care placements, the record shows that the subject materials have not been effectively disseminated. Indeed, all three Social Workers IIs working in this area reported that they were unaware of any such materials and as a result, do not consciously follow the same in carrying out their duties. The review established a more serious problem in regards to the County's actual placement practices, however. Specifically, as noted above, placement determinations in Mobile County are the primary responsibility of the Social Worker IIs in the "Foster Care Resource Unit". They testified during the course of OCR's review that generally children are placed in homes assessed to be the best suited for their overall situation.

These assessments involve consideration of a number of factors such as sex, age, and other matters. Significantly, however, they also reported that race was a determinative factor in this process as each testified that every effort is made to place children with parents if the same race. Consistent with this admitted practice, staff reported that there were no transracial placements in the County during the time of OCR's on-site visit. Records reviewed by OCR did disclose that at least five such placements occurred in calendar year 1997 since during this time there were 3 Black parents who had White children; 1 White parent who had a Black child; and there was 1 White parent with a Native-American child. However, the records reflect, and staff confirmed, that each such placement was on a temporary or emergency basis. According to staff, consistent with their practice as indicated earlier transracial placements are considered short-term options, and in those rare instances they are required to be made, the search continues for a suitable, same-race placement. They reported that trans-racial pairings last only for as long as it takes them to secure suitable, long-term, same-race placements.

Thus, similar to the situation that existed in Montgomery, the evidence discloses that staff in Mobile County also acknowledges abiding by a practice which facially require the placing of children with members of their own race, except perhaps for short-term, emergency situations. Maintaining the admitted practice of making placement determinations on the basis of race is likely to cause program participants to experience placement delays or denials in violation of their rights as provided under Title VI/MEPA. Addressing this violation will require the implementation of corrective measures such as those proposed above to address a similar problem in Montgomery.

Jefferson County

The Jefferson County Department of Human Resources has adopted the non-discriminatory written foster care policies and procedures promulgated by DHR which are also in effect in the previous two locales. Our review established that the Speciality Section, Foster Care Resource Unit of the Jefferson County Department of Human Resources (JCDHR) has primary responsibility for locating foster care placements for children, recruitment, approving licensing, and support of foster homes. Information obtained during the investigation disclosed that JCDHR conducts on-going recruitment efforts which include minority communities. According to 1990 census data, the racial composition of the total population of Jefferson County was as follows: approximately 64% White; 35% Black; 1% other. Data demonstrate that during 1997 the racial composition of the children in the foster care program in Jefferson County was 20% White and 80% Black. During this time, records show that the County's recruitment campaigns resulted in applications from prospective foster parents reflective of the racial make-up of the children in its foster care system.

In particular, of the 103 total applications received, 76, or 74%, were from Black citizens, while 24, or 23%, came from Whites, and 3, or 1%, were listed as other. As of May 27, 1998, records show that the JCDHR had a total of 174 approved foster parents. Of this group, there were 127 (73%) Blacks, and 47 (27%) Whites. There was no evidence indicating that during the licensing process Blacks were subjected to different policies/procedures, and/or, in any way improperly restricted in their ability to become foster parents. Accordingly, the evidence gathered by OCR tends to reflect that the County's recruitment and licensing policies and procedures comply with Title V/MEPA Our review also examined evidence addressing the criteria and processes used by JCDHR to place children in foster homes. In this regard we interviewed 19 members of JCDHR's staff; reviewed the records pertaining to 9 foster parents; examined the files of 89 foster children; and evaluated data obtained from various "AWIA" reports.

These investigative efforts demonstrated that during the licensure process, most notably, during the "Training and Family Profile" which is a part of the Group Preparation and Selection (G.P.S.)Training", JCDHR inquires as to the prospective parent's willingness to accept children of a different race. If the parent answers in the affirmative. He/she must go on to address questions concerning how the child might be received by the parents' extended family, friends, neighbors, schools, etc. The parents' responses to these inquiries are included in their file along with other information obtained during the licensing approval process. Generally, such inquiries of prospective parents are appropriate, particularly if they are used to enable an agency to acquire information pertinent to an assessment of their willingness and/or capacity to meet the specific needs of particular children. However, preceding this permissible line of questions, JCDHR's training materials contain an inappropriate policy statement regarding transracial placements. The record further shows that JCDHR uses the information obtained from the parents' response to these legitimate inquiries in questionable and unaccepted ways.

Specifically, JCDHR's policy on cross racial/cultural placements provides as follows: "Our agency tries to place children with families of their own race or culture. Sometimes this is not possible". During the OCR's on-site visit, staff confirmed that the agency pursues the policy of attempting to match children with families of their own race. As discussed in greater detail above, policies of this nature which explicitly dictate that suitable placements be determined in a sequence premised solely on the race of the child and prospective parents may result in prohibited delays and/or denials. They also tend to be inherently problematic since either the type of assessment criteria (i.e., temporary, emergency, long-term, etc.,) prospective parents are subject to involving transracial situations, or the actual sequence (i.e., same race prospects considered first) in which they are evaluated in these cases, are based solely on race. Consequently, this policy as articulated in the training materials violates Title VI and MEPA.

Staff testified that while same-race placements are attempted initially, they also noted that when this was not feasible transracial placements were made. In particular, it was stated that usually due to limited resources such as bed unavailability, staff was not always successful in securing a same race placement. In such instances, purportedly transracial placements are then pursued. Placement data obtained by OCR or 1997 tend to support these statements.

Specifically, records reviewed by our office demonstrate that during 1997 JCDHR made 395 placements of which 271, or 68.6% involved Black children, while 122, or 30.8%, involved White children and 2, or .5% involved other groups (i.e., 1 Hispanic White, and 1 Asian-American). Data exhibit that of the total placements, 60 or 15%, were transracial, and 335, or 85%, were same-race placements. The trans-racial placements involved: 52 Black children, or approximately 87% of the total, being placed with White parents; 6 White children, or 10% of the total, being placed with White parents; 6 White children, or 10% of the total, being placed with Black parents; 1 Hispanic child being placed with White parents; and 1 Asian-American child being placed with Black parents. Data reflect that the average length of stay for children in transracial placements was 33.1 days as compared to an average of 37.1 days for same-race placements.

Additional data also disclosed that as of June 3, 1998, the JCDHR had a total of 457 children in foster homes. Of this total, 368 were Black, 83 were White, 3 were Asian, 2 were Hispanic, and 1 was a Native-American. There were 58 transracial placements, 47 of which involved foster family "boarding homes" wherein 36 Black child were placed with White parents; 1 Black child placed with Native-American parents; 1 Black child with Asian parents; 3 White children were placed with Black parents ; 2 Hispanic children were paired with white parents; 1 Hispanic child placed with Black parents; and 3 Asian children with White parents. Records also revealed that there were 11 transracial placements in therapeutic foster homes which involved 2 Black children placed with White parents; 3 Black children in homes with Asian parents; 5 White children living with Black parents; and 1 Native-American child in the home with Black parents. During our review we also examined the files of a total of 89 children (65 Black, 19 White, 1 Hispanic, 2 Bi-racial, 2 Native-American) to determine if the records showed that placements were being delayed or denied as a result of the County's same-race placement policy. There was no evidence that the subject policy had actually caused either circumstance to occur. In addition, race did not appear to be a consideration in the removal of any of the 60 transracial placements mentioned above as the records reflect that 7 children in this category were removed to be placed with relatives; 5 were returned to their natural parents; 2 were runaways ; 5 were based on "provider's request"' 14 were due to decision of the caseworkers; and 7 were removed for unspecified reasons. While the files do not in most cases document what served as the basis for "caseworker's decision" or "provider's request", we note that there was no indication that the race of the affected children or foster parents was a factor.

The evidence gathered by OCR fails to demonstrate that foster care placements in Jefferson County have been delayed or denied on the basis of the race of the children or the prospective parents. However, the record reveals that JCDHR has a written policy which specifically provides that the agency will attempt to place children with families with similar racial backgrounds. The evidence further shows that staff at JCDHR admitted to a practice of initially attempting to make same-race placements before other suitable alternatives are pursued. The application of JCDHR' placement policy and/or practice which explicitly is based on the race of the children and/or parents involved, is likely to result in the violation of program participants' rights as provided under Title VI/MEPA.

FINDINGS AND RECOMMENDATIONS

Bases on the foregoing, OCR finds that the placement practices in all three counties, and JCDHR's written policy regarding cross racial/cultural placements, violate Title VI/MEPA and implementing regulation at 45 C.F.R. Sections 80.3 (a), (b)(1)(I), (ii), (iii),(iv),(v),(vi), and (b)(2).

OPPORTUNITY FOR VOLUNTARY COMPLIANCE

OCR provides recipients who have failed to comply with applicable statutes or regulations an opportunity to take corrective action necessary action to remedy existing violations or to overcome deficiencies which may limit their ability to conduct their programs in a non-discriminatory manner. OCR stands ready to assist DHR in securing voluntary compliance. If compliance cannot be secured by voluntary means, it may be effected by the suspension or termination of, or refusal to grant or to continue Federal financial assistance, or any other means authorized by law. Such means may include, but are not limited to a referral to the Department of Justice with a recommendation that appropriate proceedings be brought to enforce any rights of the United States under applicable Federal law, assurance or contractual undertaking . 42 U.S.C. Sections 2000d-1 and 45 C.F.R. Sections 80.8.

Within thirty (30) days of receipt of this letter, DHR may either enter into a voluntary compliance agreement with remedial measures similar to the one enclosed herewith, or submit a corrective action plan to OCR which likewise contains appropriate measures addressing the deficiencies and violations discussed above. Acceptable remedial action will have to involve an obligation by DHR to institute steps to have each county discontinue the admitted same-race placement practices, to have JCDHR rescind its written same-race placement policy, and a commitment that DHR will take other appropriates steps similar to those set forth in the proposed voluntary agreement enclosed herewith.

PROHIBITION AGAINST RETALIATION

You should be advised that pursuant to 45 C.F.R. Sections 80.7(e), participants in this investigation may not be intimidated, threatened, or coerced by DHR or other covered representatives of the agency or other persons because she/he testified, assisted or participated in any manner in an investigation, proceeding or hearing held in connection with this review.

RIGHTS OF PERSONS TO FILE CIVIL ACTIONS

Please note that OCR determinations do not effect the right of an aggrieved party to file a private civil action to remedy alleged discrimination by a recipient of Federal financial assistance. Also, no recipient may intimidate, threaten, coerce or discriminate against an individual because he or she has made a complaint, testified, assisted or participated in any manner in an action to secure rights protected by the civil rights statutes enforced by OCR. We will advise the Administration for Children and Families (ACF), also of DHHS, of our findings. ACF may make separate findings and determinations based on regulations and statues it enforces.

DISCLOSURE OF RECORDS

Under the Freedom Of Information Act, it may be necessary for OCR to release this document and related correspondence and records upon request. In the event OCR receives such a request, we will seek to protect, to the extent provided by law, personal information the disclosure of which would constitute an unwarranted invasion of privacy.

The OCR wishes to thank DHR for te courtesies extended to our staff during the course of this review. If assistance is needed with your compliance efforts, please do not hesitate to contact me as soon as possible at the address on the letterhead or by phone at (404) 562-7886.

Sincerely
Roosevelt Freeman
Acting Regional Manager
Office for Civil Rights
Region IV
cc: Mr. W. Ken Jackson,
Interim Southeast Regional Hub Director
Administration for Children and Families
U.S. Department of Health and Human Services
Enclosure